1. Introduction Nanook - Sport Ltd. (hereafter referred to as provider, data controller) as a data controller is obliged to acknowledge the contents of this legal notice. You are responsible for ensuring that all data management related to your activity meets the requirements set out in this Code and the applicable legislation. The privacy policies of Nanook-Sports Ltd. data management are continuously available at www.nanooksiiskola.hu. Nanook - Sport Ltd. reserves the right to change this information at any time. Of course, you will notify your audience in due time of any changes. Nanook - Sport Ltd. is committed to protecting the privacy of its clients' information and self - determination rights in order to protect the privacy of their clients and partners. Nanook - Sport Ltd. treats your personal data in confidence and will take all security, technical and organizational measures that guarantee the security of your data. Nanook - Sport Ltd. describes the data management principles below and presents them expectations that he has formulated against himself as a data controller and is complying with it. The data management principles are in line with existing data protection legislation, in particular: • 2011 CXII. law on information self-determination and freedom of information; • Act V of 2013 - Civil Code (Civil Code); • Act C of 2000 on Accounting (Accounting); • CVIII of 2001. Act on Electronic Commerce Services and Certain Issues of Information Society Services (Eker. • Act C of 2003 on Electronic Communications (Eht.); • Act XLVIII of 2008. Act on the Fundamental Terms and Limitations of Economic Advertising (Grt.).

2. Definitions

2.1. concerned: any natural person identified or identified, directly or indirectly, by any specific personal data;

2.2. personal data: the data that may be associated with the data subject, in particular the name, identifying mark, and the knowledge of one or more physical, physiological, mental, economic, cultural or social identities of the data subject, and the deductible conclusion;

2.3. contribution: voluntary and decisive declaration of the wishes of the person concerned, based on appropriate information and giving him an unmistakable to cover all or part of the relevant personal data;

2.4. Data Controller: Not a natural or legal person or a legal entity a body that independently or with others determines the purpose of data management, makes and executes decisions on data handling (including the equipment used) or performs it with the data processor;

2.5. data management: irrespective of the method used, any operation or aggregation of data, such as collecting, recording, recording, systematizing, store, modify, use, query, transmit, disclose, align or link, block, delete, or delete data as well as prevent further use of the data, take photographs, audio or images and physical properties (eg finger or palm print, DNA pattern, iris image) suitable for identifying the person;

2.6. transfer of data: making the data available to a specific third party;

2.7. disclosure: making the data available to anyone;

2.8. data deletion: making data unrecognizable in such a way that their recovery is no longer possible;

2.9. data processing: performing technical tasks related to data management operations, irrespective of the method and device used to perform the operations, provided that the technical task is carried out on the data;

2:10. "data processor" means a natural or legal person or an organization with no legal personality, or who, on the basis of a contract, including a contract under a provision of the law, processes the data.

3. The scope of personal data, purpose, title and duration of data management

The data management of the activities of Nanook - Sport Ltd. is based on a voluntary contribution.

In some cases, however, the management, storage, and transmission of a particular set of data are made mandatory by law, and we will notify our audience separately. We invite Nanook - Sport Ltd. to inform the information that it is not personal

their data is provided, it is the duty of the data supplier to obtain the consent of the person concerned.

Purpose of data management: During a visit to the site, the service provider records the visitor data to monitor the operation of the service, to provide personalized service and prevent abuse.

Legal Basis for Data Processing: Contribution of the Contributor and CVIII of 2001 on certain aspects of information society services. Law 13 / A. § (3).

The range of data processed is the date, time, IP address of the user's computer, data on the browser of the user's computer, and the address of the visited page.

The duration of the data management is 30 days from the date of viewing the site.

Nanook - Sport Kft. Does not link data collected during the analysis of log files with other information and does not seek to identify the user.

The IP address is a series of numbers that can uniquely identify users of Internet users. IP addresses can also geographically locate a visitor using that computer. The address of the pages visited and the date,

date data are not suitable for the identification of the individual, but are linked to other data (such as those provided during registration) to help draw conclusions about the user.

This website may contain links that may be transmitted to other providers' websites where this statement / practice is not valid.

Data collected from you can be used for different purposes. Data management is based on the following legal bases:

1: Request for inquiries, interest in our Services website, personally, by phone, e-mail or other means

- In the course of your request, you must provide the following personal information: name, e-mail address, telephone number, subject

- the purpose of the data management is to contact and maintain contact with the Data Provider Services, provide information, clarify the interest, and send a personalized offer.

- the legal basis for data handling is your consent.

- data processing takes place until the consent is withdrawn.

2: Sign up for a newsletter (on our site on the subscription page or in person, by phone, orally, in writing, by e-mail)

- When signing up for a newsletter, we need the following personal information: email address, name. You are responsible for the authenticity of the personal data provided.

- Entering the email address is essential for the delivery of the messages. Nanook - Sport Kft. Handles newsletter subscribers with online newsletters and messages featuring news, news and offers.

- the legal basis for data handling is your consent.

- data processing takes place until the consent is withdrawn. At the bottom of our newsletters there is an unsubscribe link at which you can unsubscribe at any time.

- the legal basis for data handling is to ensure the protection of accident protection considerations and the settlement of any disputes arising in connection with it.

4. The duration of the processing is the year of completion of the contract, plus 10 years.

Data logging for external service providers:

The html code of the portal contains references to external and external servers independent of Nanook - Sport Ltd. The external service provider is connected directly to the user's computer. We call on our visitors to note that the providers of these links are able to collect user data (eg IP address, browser, operating system data, visited page title, and date of visit) due to direct connection to their server by direct communication with the user's browser.

Potentially personalized content for the user to the external server

The html code of the portal contains references to external and external servers independent of Nanook - Sport Ltd. The external service provider is connected directly to the user's computer. We call on our visitors to note that the providers of these links are able to collect user data (eg IP address, browser, operating system data, visited page title, and date of visit) due to direct connection to their server by direct communication with the user's browser.

Potentially personalized content for the user is served by the external service provider. The relationship between Nanook - Sport Ltd. and the external service provider only covers the insertion of the latter code, so no personal data is transferred or forwarded.

Data management for webauditing and hosting of the website visitor data is a widespread data management on the Internet, so the user accepts them on the internet by visiting web sites.

The data controllers listed below can provide detailed information on the management of data by external service providers.

independent measurement and auditing as an external service provider is assisted by the Google Analytics server. For details on managing measurement data, go to http://www.google.com/intl/en/policies/ for details.

To keep your ads personalized, Google AdWords is also directly linked to Facebook and www.google.com/doubleclick service providers

We need some information and data to operate Nanook - Sport Ltd. and to provide our services. By accepting the Privacy Policy, you are provided with our understanding that you have read and understood our data management practices and how we can collect and use your information.

If you do not agree with our Privacy Policy, we must ask you to sign up for our newsletter.

3.2. Client's request for Nanook-Sport Kft

If you have any questions or concerns when using our services, you can contact the data administrator at the contact details provided in this brochure.

Nanook - Sport Kft. Receives the received emails with the sender's name and e-mail address and other voluntary personal data, up to a maximum of five

after one year.

3.3. Other data management

Data can be used for different purposes. Data management is based on the following legal bases:

- Obtaining a Contract, Providing a Service: Your personal data may be needed to comply with the contract between us and to provide you with our services.

- Contribution: We may request your consent to use your personal information, for example, in order to use them for marketing purposes. THE

you can withdraw it at any time.

- Reasonable cases: We may use your personal information in justified cases, for example, to improve, improve the functionality of our services and to meet the most useful content on our website, email notifications, and newsletters.

In addition, we may use your personal information for administrative or legal reasons.

- Provide information to our contributing partners: As part of the organization of travel, we have to share some information with our contributing partners in the organization (eg travel agents, tour operators,

in the case of contracted roads, third parties involved in the performance of the contract, accommodation, incoming offices). Shared information may include, but is not limited to

- We use the data we use for authentication, authentication, billing and payment purposes, for targeted online and offline marketing. In addition, the information can be used to settle the dispute with Nanook - Sport Kft. For similar reasons, we can run promotional ads on various platforms, including Facebook and Google ad systems.

We inform our clients that, for the purpose of providing information, transmitting information or submitting documents, other bodies may, by virtue of the authority of the court, the public prosecutor, the investigating authority, the offending authority, the administrative authority, the National Data Protection and Information Authority, controller.

Nanook - Sport Ltd. - to the public authorities - provided the authority has indicated the exact purpose and scope of the data - issues personal data only to and to the extent that the

The data processor ensures proper data storage and the introduction of security measures to protect the data.

Nanook - Sport Kft retains its data handling

(a) confidentiality: it protects the information so that it can only access the person who is entitled to it;

(b) integrity: it protects the accuracy and completeness of the information and the method of processing;

c) Availability: Ensures that when the eligible user needs it, he / she can actually access the information required and have access to the related tools.

The IT system and network of Nanook - Sport Ltd. and its partners are protected against computer - aided fraud, espionage, sabotage, vandalism, fire and flood, as well as computer viruses, computer burglaries, and attacks leading to denial of service. The operator provides security through server-level and application-level security procedures.

We inform the users that electronic mails, protocols (email, web, ftp, etc.) transmitted over the Internet are vulnerable to network threats that lead to dishonest activity, controversy or disclosure or modification of information. To protect such threats, the data controller will take all the precautionary measures he or she may have to take. The systems are monitored in order to record and provide evidence of any security disruption

for each security event. System monitoring also allows checking the effectiveness of the precautions used.

You may request the information concerned to handle your personal data and may ask for personal information

as well as, with the exception of mandatory data handling, deletion or blocking in the manner indicated in your data logging or customer service.

Right to information:

At the request of the person concerned, Nanook - Sport Kft. As a data controller shall provide information about the source, the purpose, legal basis, duration of the data processing, the name and address of the data processor, the data of the data processor and the data processed by the processor he /

data-related activities and, in the case of data transmission, its legal basis and addressee. The data controller shall, within the shortest possible time, but not later than 30 days after the submission of the application, in a comprehensible form, at the request of the data subject concerned

enter the information in writing. This information is free of charge if the request for information has not yet been filed with the data controller for the same data field during the current year.

In other cases, Nanook - Sport Ltd. shall set a cost reimbursement.

Correction Right:

Nanook - Sport Kft corrects your personal data if it does not meet the reality and has the right personal information.

Lock and mark:

Nanook - Sport Ltd. locks out personal data when requested by the data subject or if, based on the information available to it, it can be assumed that deletion would harm the legitimate interests of the data subject. Blocked personal data can only be handled as long as the data management goal exists,

which excluded the deletion of personal data.

Nanook - Sport Ltd. treats the personal data it manages if the person concerned disputes its correctness or accuracy, but the incorrect or imprecise nature of the disputed personal data is not

can be clearly stated.

Right to cancel:

Nanook - Sport Ltd will disclose personal data if its handling is unlawful, the person concerned requests, the data in question is incomplete or incorrect - and this condition can not be legally remedied - provided that the deletion is not excluded by law, the purpose of data management has ceased or the the deadline for storage of data expired by law is passed by the court or the National Privacy and

Freedom of Information Authority ordered.

Procedural rules:

The data controller has 30 days to delete, block or correct the personal data

disposal. If the data controller fails to comply with the correction, blocking or cancellation concerned, he or she shall state the reasons for the rejection within 30 days.

and notifies those who previously forwarded the data for data processing purposes. It fails to be notified if it does not prejudice the legitimate interests of the data concerned for the purposes of data management.

Right to protest:

The person concerned may object to the handling of his or her personal data if:

(a) the processing or transmission of personal data is only necessary to fulfill the legal obligation of the data controller or to enforce the legitimate interests of the data controller, the data entrant or third party, unless data management is prescribed by law;

(b) the use or transmission of personal data is done for direct business acquisition, polling or scientific research;

c) in other cases specified by law.

Nanook - Sport Kft shall examine the protest within the shortest possible time, but within a maximum of 15 days, on the grounds of its validity, and shall inform the applicant in writing. If the data controller establishes the validity of the protest of the data subject, data handling, including further data collection and

it also deletes data and deletes the data, and notifies the protest and the measures taken on the basis of those who have been previously transferred to the personal data affected by the protest and who are required to take action in order to enforce the right to protest.

If the data controller disagrees with the decision of the data controller, he or she may appeal to the court within 30 days of the communication.

The data of Nanook - Sport Kft. Can not be erased if data management is ordered by law. However, the data can not be transmitted to the data sender if the data controller agrees with the protest, and the court has found the right to protest.

Damage and damages:

Nanook - Sport Ltd reimburses any damage caused to others by unlawful handling of the data concerned or breach of the requirements of data security. In the event of a breach of the personality right of the person concerned, the injured party may be required to pay the fee (new paragraph 2:52).

The data controller is also responsible for the damage caused by the data processor to the data subject.

The data controller is exempted from liability if the damage is caused by an unavoidable cause outside the scope of data management.

The Data Handler does not compensate for the damage and can not be claimed for damages insofar as damages caused by the injured party or the infringement of personality rights have come from the deliberate or grossly negligent conduct of the person concerned.

Right to Court:

In case of breach of his or her rights, the data subject may turn to the court. The court proceeds out of court.

Privacy Policy Procedures:

You can lodge a complaint with the National Privacy and Freedom Authority: Name: National Data Protection and Freedom Authority